Privacy Policy

Privacy Policy EFFECTIVE April 26, 2018 NOTE: The North River Farms Website Privacy Policy (“Privacy Policy”) has been updated and applies to the North River Farms website (www.livenorthriverfarms.com) and all other websites operated, maintained and/or managed by Integral Communities, its affiliates and subsidiaries (said websites individually and collectively referred to in this Privacy Policy as the “Integral Communities Website”). Please review the updated Privacy Policy carefully before using the Integral Communities Website. By using the Integral Communities Website, you consent to the terms of the updated Privacy Policy.

1. INTRODUCTION Integral Communities, its affiliates and subsidiaries (collectively, the “Company,” “us” or “we”) respect your privacy and are committed to treating your information responsibly. To that end, we have developed the following Privacy Policy to provide full disclosure concerning our collection, use and sharing of information that is gathered during your interaction with the Integral Communities Website. This Privacy Policy describes, among other things, the types of information collected about you when you visit the Integral Communities Website; how your information may be used and when it may be disclosed; how you can control the use and disclosure of your information; and how your information is protected. Trust is a cornerstone of the Company’s mission, and we are committed to gaining and maintaining your trust by following the privacy and security principles that are set forth in this Privacy Policy. However, it is important to recognize that “perfect security” does not exist on the Internet. Therefore, while we endeavor to maintain appropriate physical and electronic procedures and safeguards to protect personal information that is collected by and through the Integral Communities Website, we cannot guarantee the confidentiality of such information. Accordingly, by using the Integral Communities Website, you understand that (i) you are doing so at your own risk and (ii) the Company cannot promise that collected information will never be disclosed in a manner that is inconsistent with this Privacy Policy. Should you have any questions regarding this Privacy Policy, or if you believe that we are not abiding by this Privacy Policy, please contact the Privacy Administrator at the address set forth in Section 14, below.

2. SCOPE OF PRIVACY POLICY; ACCEPTANCE This Privacy Policy applies to information collected about you and from you – by and through the Integral Communities Website. Your use of the Integral Communities Website constitutes your consent to the Company’s collection and use of such information in accordance with the terms hereof. Each time you access, use or browse the Integral Communities Website, you signify your acceptance of the Privacy Policy (in its then-current form). If you do not accept this Privacy Policy, you are not authorized to use the Integral Communities Website and must discontinue use of the Integral Communities Website immediately.

3. INFORMATION THAT WE COLLECT The Company collects two (2) types of information by and through the Integral Communities Website: Personal Information and Non-Personal Information. A. Personal Information. Personal Information is information that tells us specifics about you. The types of Personal Information that we may collect include, without limitation: your name and contact information (such as your postal address, zip code, phone number or e-mail address); your gender; the number and/or ages of members of your household; information about the type of properties you are interested in and other general information relating to product preferences; if (and when) you are planning to move from your current domicile; personal interests; household income; and areas of interest on the Integral Communities Website. We will not collect any Personal Information about you through the Integral Communities Website unless you provide it to us voluntarily. However, please be aware that the Company may track and record the Internet Protocol (“IP”) address from your computer or other device. [If we do track/record you’re the IP address assigned to your computer/device, we will not link the IP address to any Personal Information.] Moreover, please be advised that the Company may also acquire Personal Information about you from publicly available sources, social media platforms (e.g., Facebook) and other third parties that may share information as permitted in their privacy policies. Also note that the Company may combine Personal Information about you with information available from other sources (e.g., social media platforms, analytics services [see Section 5.B, below], offline records or publicly available information). If the combined information is maintained, used or shared by the Company in a manner that associates it with your name or contact information, we will treat such information as Personal Information. B. Non-Personal Information. Non-Personal Information refers to data and information that does not personally identify you as the individual to whom the data or information relates. Non-Personal Information may include, without limitation: • The IP address assigned to your computer (or other device); • Your media access control (MAC) address; • Information derived through Collection Technology (see Section 5.A, below); • The type of computer (or other device) you use, and the operating system you use (e.g., Microsoft Windows or Mac OS); • The type of Internet browser you use (e.g., Internet Explorer, Google Chrome or Safari); • The domain name of your Internet Service Provider; • Your activities while visiting or using the Integral Communities Website (including the content you access or view, the time of your visit to or use of the Integral Communities Website, and the pages you visit and the time spent on such pages); • Your general geographic location (such as the city from which your computer or device is connecting to the Internet); and • Information regarding your Internet location when you see the Company’s ads and whether you click on such ads. The Company automatically receives and records Non-Personal Information on our server logs from your browser, as well as through other analytics in relation to the Integral Communities Website. We may also obtain Non-Personal Information about you either directly or through inference from social media platforms, third parties and other lawful sources.

4. USE AND DISCLOSURE OF INFORMATION The information we collect will vary depending upon how you use the Integral Communities Website. Similarly, our use and disclosure of the collected information will vary depending on the type of information we receive – i.e., Personal Information vs. Non-Personal Information. A. Personal Information. The Company may use your Personal Information to: • Carry out the purposes for which you provided the information to us (e.g., provide your contact information to homebuilders to enable them to follow-up with you on your requests, or enroll you in a sweepstakes sponsored by the Company); • Keep you apprised of events, information and developments regarding the Company’s activities (as well as other items that you may find of interest); • Customize the content or functionality of the Integral Communities Website to your preferences; • Inquire as to whether you would like to receive any additional information regarding the Company’s products, services, master planned communities and homebuilders; • Forward or otherwise provide updates, announcements and newsletters regarding the Company’s products, services, master planned communities and homebuilders; and • Respond to your communications and questions. The Company may intentionally disclose your Personal Information only in the following instances: i. Disclosures to Homebuilders. The Company will provide your Personal Information to those homebuilders that you have designated (using the Integral Communities Website or otherwise) to receive your information so that the homebuilders can contact you to address your questions and requests. However, the Company is not responsible for the collection or maintenance of such information once it is in the homebuilders’ hands. ii. Disclosures to Which You Have Consented. The Company may disclose your Personal Information if you have consented (whether expressly or implicitly) to said disclosure. By way of example only, if (i) you elect to participate in a sweepstakes sponsored by the Company and (ii) the official rules of the sweepstakes declare that the Company may publish the names of (and other information regarding) the sweepstakes entrants and/or winners, then, by virtue of your decision to participate in the sweepstakes, you are deemed to have consented to the official rules and the disclosure of your Personal Information in accordance with the rules. iii. Disclosures to Trusted Third Parties. The Company may provide your Personal Information to trusted operators who work on behalf of or with the Company, provided that (i) the disclosure is necessary or otherwise convenient in connection with assisting the Company in its operations and (ii) said trusted operators work under confidentiality or similar agreements. iv. Disclosures under Special Circumstances. The Company may store and disclose your Personal Information (i) as allowed or required by applicable law (including making disclosures in order to respond to subpoenas, court orders or legal process) and (ii) to establish or exercise our legal rights or defend against legal claims as necessary or advisable to protect the rights, safety or property of the Company or others and to conform to legal or regulatory requirements. Additionally, we may store and disclose your Personal Information when we believe it is necessary to share such information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Integral Communities Website TERMS OF USE, or as otherwise required by law. B. Non-Personal Information. The Company may use your Non-Personal Information in several ways including, but not limited to: • Administration of the Integral Communities Website; • Improvement of the Integral Communities Website (including improving your navigation of the Integral Communities Website upon your return visit); • Improvement of the products and services offered by the Company (including project planning); • Analysis and development of advertisements and advertising campaigns; • Providing you with special offers and promotions (and determinations regarding their effectiveness); • Customization of the content or functionality of the Integral Communities Website to suit your preferences; and • Analysis of trends and usage of the Integral Communities Website. The Company may disclose your Non-Personal Information to employees, consultants and other professionals who we reasonably believe need such information in order to perform the tasks described in this Section 4.B. Additionally, the Company may combine your Non-Personal Information with other non-personal information collected by the Company and share the aggregated data with homebuilders, service companies and product providers for marketing and research purposes.

5. COMPANY’S USE OF COLLECTION TECHNOLOGY AND ANALYTICS SERVICES A. Collection Technology. Non-Personal Information may be collected by the Company using a variety of Collection Technology. As used in this Privacy Policy, “Collection Technology” refers to cookies, web beacons, pixels, gifs, tags and other tools that collect information in similar ways. Collection Technology may store a piece of data on your browser or device, while other forms of Collection Technology may identify your browser or device and collect information through other means. When you visit the Integral Communities Website (or another website), your browser or device may be exposed to Collection Technology, and Collection Technology may be stored on your browser or device. The Company may access, retrieve and use the Non-Personal Information generated and stored by the Collection Technology on your browser or device. You may delete and/or refuse the use of certain Collection Technology by selecting the appropriate settings on your browser. And, you are not barred or precluded from using the Integral Communities Website if you choose to delete and/or refuse such Collection Technology. However, please note that some parts of the Integral Communities Website may not work properly if you elect to delete and/or refuse Collection Technology. A. Analytics Services. The Company may use third-party analytics services to facilitate the compilation, tracking and analysis of information that is accumulated using Collection Technology. For example, the Company may use Google Analytics to measure, analyze and report on data gathered through Collection Technology to assist the Company in understanding and optimizing use of the Integral Communities Website. Information and data collected through the Company’s use of analytics services shall be used and shared by the Company solely in conformance with this Privacy Policy. However, please be advised that third-party analytics services are governed by their own privacy policies, and the Company has no control over the scope, limitations or requirements of these policies. Should you have any questions regarding the Company’s use of analytics services, please contact the Privacy Administrator at the address identified in Section 14 of this Privacy Protocol.

6. PROTECTION OF INFORMATION The Company is committed to protecting your Personal Information. Accordingly, we have adopted commercially reasonable technical, administrative and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access and alteration. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure (e.g., third party “hackers” may unlawfully intercept or access information or confidential transmissions). We want you to feel confident using the Integral Communities Website; but, as indicated in Section 1, above, we cannot ensure or warrant the security of any information you transmit to us and any such transmission is done at your own risk.

7. LINKS TO THIRD-PARTY WEBSITES The Integral Communities Website may contain links to third-party websites for homebuilders, community associations, retailers, service providers and others, which are provided solely as a convenience to viewers of the Integral Communities Website and not as an endorsement of the contents of such websites. Although we endeavor to provide links only to websites maintained by reputable entities and organizations, you should be aware that these third parties might be able to gather information from and about you if you visit their websites. In these cases, those third parties will use such information in accordance with their own privacy policies, which may differ substantially from our Privacy Policy. We strongly encourage you to read the privacy policies of these third parties. We assume no liability for the privacy practices of such other websites and are not responsible for the availability or content of any off-site pages or any other websites linked to the Integral Communities Website. Your linking to off-site pages or other websites is at your own risk.

8. CORRECTION OF PERSONAL INFORMATION; OPT-OUT RIGHT The Company endeavors to keep your Personal Information current and accurate. Accordingly, we ask that you notify us of any changes to your Personal Information via e-mail, telephone or postal mail at the addresses shown in Section 14, below. You may at any time opt-out of having your Personal Information used by the Company for mailings, calls, etc. by notifying us via e-mail, telephone or postal mail at the addresses shown in Section 14, below. If you elect not to receive any future contacts from the Company, we will endeavor to remove your name from all of our contact lists within ten (10) business days. However, information is sometimes difficult if not impossible to remove from all data sources and, accordingly, we can only promise to endeavor to remove you from any lists that we control. We shall have no liability for our failure to accomplish this objective.

9. CHILDREN Naturally, the safety of children is very important to us, and the Company is committed to protecting the privacy of children. In this regard, (i) the Integral Communities Website is directed to persons 18 years of age or older and (ii) the Company does not knowingly collect information from children under the age of 18. If you provide Personal Information to the Company through the Integral Communities Website, you represent and warrant to the Company that you are 18 years of age or older. If you are under the age of 18, you may visit, browse and use the information on the Integral Communities Website, but you may not submit any Personal Information to the Integral Communities Website and you represent and warrant to the Company that you have the permission of your parent or guardian to use the Integral Communities Website. If we become aware that a user of the Integral Communities Website is under the age of 18 and has provided Personal Information, we will remove said information from our files.

10. NOTICE TO CALIFORNIA RESIDENTS – YOUR PRIVACY RIGHTS Under California’s “Shine the Light Law” (Cal. Civ. Code Section 1798.83), California residents are entitled to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. You may make such a request by sending an e-mail or letter to us at the following address: Privacy Administrator Integral Communities 888 San Clemente, CA 92660 Newport Beach, California 92660 Phone: 949-720-3612 Email: info@integralcommunities.com As indicated in Section 1, above, trust is an essential part of the Company’s mission, and we take great pride in the relationship of trust that we have built with our customers. In furtherance of our commitment to trust, the Company has adopted a policy of not selling, renting or sharing your Personal Information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure (e.g., your request that we send your Personal Information to homebuilders so that they may contact you directly regarding their neighborhoods and products).

11. PRIVACY POLICY EFFECTIVENESS This Privacy Policy shall apply only to individual consumers and solely to information collected by or through the Integral Communities Website.

12. CHANGES IN PRIVACY POLICY This Privacy Policy may be revised from time to time in the Company’s sole discretion. We display a “Last Modified” date on the upper left corner of the Privacy Policy for you to know when there has been a change in the Privacy Policy. Accordingly, you should check the Privacy Policy on a regular basis for the Company’s most current privacy practices. Each time you access, use or browse the Integral Communities Website, you signify your acceptance of the then-current version of this Privacy Policy. Any changes in this Privacy Policy will take effect upon posting. We will use information collected by and through the Integral Communities Website in accordance with the version of the Privacy Policy in effect as of the date the information was collected. If we, at any point, decide to use Personal Information in a manner that is materially different from that stated at the time it was collected, we will provide you with notice or have other communications with you in the manner and to the extent required by law.

13. GOVERNING LAW This Privacy Policy shall be governed by, and shall be construed in accordance with, the laws of the State of California, without regard to choice of law principles.